Introduction

This privacy policy notice is for this website elcox.co.uk and all subdomain installed websites, served by Elcox, United Kingdom and governs the privacy of those who use it.

This policy aims to explain how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations. 

If you do not agree to the following policy, you may wish to cease viewing/using this website.

Owner and Data Controller

Elcox The English Language Centre Oxford

6-7 Citibase,
New Barclay House,
234 Botley Road,
Oxford OX2 0HP, U.K.

Owner contact email: [email protected]

Policy key definitions

“I”, “our”, “us” or “we” refer to the business, (Elcox & other brands or trading names), “you”, “the user” refer to the person(s) using this website. GDPR means General Data Protection Regulation. Cookies mean small files stored on a user’s computer or device.

The legal basis of processing

Under GDPR Elcox may process personal data relating to users if one of the following applies:

• Users have given their free, specific, informed, and unambiguous consent for marketing content subscription (e.g. periodical newsletter)
• Provision of data is necessary for performing of an agreement with the user and/or for any pre-contractual obligations thereof
• Processing is necessary for compliance with a legal obligation to which the owner is subject
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the owner
• Processing is necessary for the legitimate interests pursued by the owner or by a third party

Elcox will help clarify the specific legal basis that applies to the processing, mainly whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Types of data collected

The user may freely provide personal data, or, in case of usage data, collected automatically when using this website. Among the types of personal data that this website collects, by itself or through third parties, there are:

• Email address, first name and last name (freely provided by the user via subscription forms, modals or other means on this website)
• Usage data and cookies (collected automatically when using this website).

Complete details on each type of personal data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed before the data collection. Unless specified otherwise, all data requested by this website is mandatory, and failure to provide this data may make it impossible for this website to provide its services. In cases where this website specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the service’s availability or functioning.

Users who are uncertain about which personal data is mandatory are welcome to contact Elcox. Users are responsible for any third-party personal data obtained, published, or shared through this website and confirm that they have the third party’s consent to provide the data to the owner.

Processing of your personal data

Mode

Elcox takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the user data. Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

In addition to Elcox personnel, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by Elcox.

The updated list of these parties may be requested from Elcox at any time.

Place

The data is processed at the owner’s operating offices and in any other places where the processing parties are located. Depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. To find out more about the place of processing such transferred data, users can check the section containing details about personal data processing below.

Retention time

Personal data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal data collected for purposes related to performing of a contract between the owner, and the user shall be retained until such contract has been fully performed.
• Personal data collected for the owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the owner’s legitimate interests within the relevant sections of this document or by contacting the owner.
• The owner may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, provided such consent is not withdrawn.
• Furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for performing of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

The purposes of processing

The data concerning the user is collected to allow Elcox to provide its services and for the following purposes: direct marketing, analytics, backup saving and management and contacting the user.

Users can find further detailed information about such purposes of processing and the specific personal data used for each purpose in this document’s respective sections.

Detailed information on the processing of personal data

Personal data is collected for the following purposes and using the following services.

Contact forms (this website)

By filling in the contact forms with their data, the user authorises this website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal data collected: first name, last name, email address, country, industry, job title and position, website URL.

Analytics

The services in this section enable Elcox to monitor and analyse web traffic and can be used to track user behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the data collected to track and examine the use of this application, to prepare reports on its activities and share them with other Google services.

Google may use the data collected to contextualise and personalise the ads of its own advertising network. 

Personal data collected: cookies and usage data.

Place of processing: U.S.A. – Privacy Policy – Opt Out. Privacy shield participant.

Backup saving and management

This type of service allows Elcox to save and manage backups of this website on external servers managed by the service provider itself. The backups may include the source code and content and the data the user provides to this website.

The data is saved and backed up at the owner’s operating offices and in any other places where the processing parties are located. Elcox might use third party services such as Google drive and DropBox.

Personal data collected: various types of data as specified in the privacy policy of the service.

Place of processing: Elcox’s operating offices are in the U.K. and the U.S.A. – Privacy policy. Privacy shield participant.

The rights of users

Users may exercise certain rights regarding their data processed by Elcox. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with Elcox to find out which rights apply to them.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously consented to their personal data processing.
• Object to the processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their data. Users have the right to learn if the owner is processing data, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, Elcox will not process their data for any purpose other than storing it.
• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from Elcox.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract which the user is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to the processing

Where personal data is processed for the public interest, in the exercise of an official authority vested in the owner or for the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the owner is processing personal data for direct marketing purposes, users may refer to this document’s relevant sections.

How to exercise these rights

Any requests to exercise user rights can be directed to Elcox through this website’s contact details. These requests can be exercised free of charge and will be addressed by Elcox as early as possible and always within one month.

Applicability of broader protection standards

While most provisions of this document concern all users, some provisions expressly only apply if personal data processing is subject to broader protection standards.

Such broader protection standards apply when the processing:

• is performed by an owner based within the EU
• concerns the personal data of users who are in the EU and is related to the offering of paid or unpaid goods or services, to such users
• concerns the personal data of users who are in the EU and allows the owner to monitor such users’ behaviour taking place in the EU
• additional information about data collection and processing

Legal action

The user’s personal data may be used for legal purposes by Elcox in court or in the stages leading to possible legal action arising from improper use of this website or the related services.

The user declares to be aware that Elcox may be required to reveal personal data upon public authorities’ request.

Additional information about user’s personal data

In addition to the information in this privacy policy, this website may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (system logs) use other personal data (such as the IP address) for this purpose.

Information not contained in this policy

More details concerning collecting or processing personal data may be requested from Elcox at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

Elcox reserves the right to change this privacy policy at any time by giving notice to its users on this page and possibly within this website and/or – as far as technically and legally feasible – sending a notice to users via any contact information available to the owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed by the user’s consent, Elcox shall collect new consent from the user, where required.

Elcox Team, December 12th, 2020